Epstein Secrets

rey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, F-sq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United State

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Ro Black to and m Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upo

d for disclosure is greater than the need for continued secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, an

nd the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek int

Victims' Rights Act The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRAJ was enacted to make crime victims f

nd the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek int

Victims' Rights Act The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRAJ was enacted to make crime victims f

nd the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek int

Victims' Rights Act The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims f

/ECF system: Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 i i FL 33131 ia Martin G. Weinberg,

decided to withhold — and victims are deprived of the chance to place that information before the Court. The Government also cites United States v. Moussaoui, 483 F.3d 220 (4th Cir. 2007). Moussaoui is completely irrelevant to this case, as it involved efforts by civil litigants to intervene in a crimina

stein's defense team included at various times attorneys from multiple law firms, such as: (1) Jay P. Lefkowitz, Kirkland & Ellis, New York, NY; (2) Roy Black, Black Srebnick Komspan & Stumpf, Miami, FL; (3) Gerald B. Lefcourt, Law Office of Gerald B. Lefcourt, P.C., New York, NY (4) Lilly Ann Sanchez, Fow

ng given that the CVRA was enacted to protect crime victims' rights and ensure their involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007);? II Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime vict

igation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstein during the investigation, are filing this pleading to provide notice to t

04/07/2011 Page 4 of 9 2007 WL 951666 at *1. Other attempts to engraft discovery rights onto the CVRA have also been rejected. In United States'. Moussaoui, 483 F.3d 220 (4h Cir. 2007), several victims in the September 11, 2001 terrorist attacks sought access to files and records provided by the governm